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Who must comply with Country of Origin Labelling for food (CoOL Information Standard)?

The applicability test for Country of Origin Labelling for food (CoOL Information Standard) (ACCC), computed across 35 industries, 9 business structures and 6 size bands.

Short answer: Only if

Applies only if you supply priority food (CoOL Information Standard). Whether it applies turns on a fact that no industry, structure or size settles on its own.

What the obligation is

Food sold in Australia must carry country-of-origin labelling per the 2016 Information Standard.

The Country of Origin Food Labelling Information Standard 2016 (made under the ACL) requires priority food sold in retail to carry CoOL labels including the kangaroo logo for products made/grown/produced/packed in Australia, plus the percentage of Australian-sourced ingredients on a coloured bar chart.

The applicability test

Applies only if you supply priority food (CoOL Information Standard). Whether it applies turns on a fact that no industry, structure or size settles on its own.

How the regulator frames it: Retailers and food manufacturers supplying priority food in Australia.

What triggers it: Supplying priority food (most food not consumed as it leaves the supplier) at retail.

Jurisdiction: Commonwealth law, so the test is the same in every state and territory.

Which industries are in or out

Outcome across the 35 industries Rules Mate maps (2 of 35: only if a further fact applies; 33 of 35: no).

IndustryAnswer
Retail tradeOnly if a further fact applies
ManufacturingOnly if a further fact applies
No33 other industries

Business structure and size

Structure does not change the answer in the 2 industries it can reach: for every structure the answer is "only if a further fact applies".

Size does not change the answer in the 2 industries it can reach: at every size band the answer is "only if a further fact applies".

Worked examples

Each line is one run of the Rules Mate applicability engine for a single business profile, with the reason the engine gives:

  • Pty Ltd company in real estate agents with 6–19 employees, turnover $1M–$3M: does not apply. Requires a trigger outside this questionnaire.
  • Pty Ltd company in retail trade with 6–19 employees, turnover $1M–$3M: check whether it applies. applies only if you supply priority food (CoOL Information Standard)

When you need to check further

The engine shows this obligation as "check whether this applies" when a business has industry: Retail trade / Manufacturing. It then applies only if you supply priority food (CoOL Information Standard). That fact is not something Rules Mate can infer from industry, structure or size.

What you must do, and when

When due
Continuous.
Frequency
Ongoing
Evidence to keep
Compliant labels, supplier declarations, percentage-of-AU calculations.
Status
Current
Priority
High

Penalty for not complying

Maximum penalty: Civil penalty up to $16.665M for false/misleading representations (ACL)

Audit or assurance level

Rules Mate has not yet classified the audit or assurance level for this obligation. Any audit, review or certification requirement is set by the regulator source listed below.

Where it sits in the corpus

Rules Mate tracks 7 published obligations tagged "consumer law", 2 of them rated critical. For a professional services Pty Ltd company with 6–19 employees operating in every state, 2 of those apply outright. This obligation is rated high priority, and is an ongoing duty.

Regulator, legislation and tools

Regulated by Australian Competition and Consumer Commission.

ACCC: Competition and consumer regulator administering the Competition and Consumer Act 2010 and Australian Consumer Law, plus industry codes and infrastructure access regimes.

CCA: Australia's competition + consumer protection law.

Free tools that help with this obligation:

Questions

Who must comply with Country of Origin Labelling for food (CoOL Information Standard)?
Applies only if you supply priority food (CoOL Information Standard). Whether it applies turns on a fact that no industry, structure or size settles on its own.
Does Country of Origin Labelling for food (CoOL Information Standard) apply to sole traders?
Only if a further fact applies. Looking in the 2 industries it can reach and every size band, the engine's answer for a sole trader is: only if a further fact applies.
Does Country of Origin Labelling for food (CoOL Information Standard) apply to businesses with 1–5 employees?
Only if a further fact applies (1–5 employees, turnover $100K–$1M).
When is "Country of Origin Labelling for food (CoOL Information Standard)" due?
Continuous.

Related

Sources

Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.